Legal Opinion

Spheeris v. Commissioner

United States Tax Court

Decided June 23, 1970No. Docket No. 7183-65Published

The S corporation had been engaged in the business of owning and operating commercial rental properties since 1945. In February 1960, one of its properties was destroyed by fire. Thereafter, various activities were engaged in on behalf of S corporation directed toward returning such property to income-producing status.

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The S corporation had been engaged in the business of owning and operating commercial rental properties since 1945. In February 1960, one of its properties was destroyed by fire. Thereafter, various activities were engaged in on behalf of S corporation directed toward returning such property to income-producing status. Because of a disagreement among the shareholders with regard to how such property should be rehabilitated, the property was transferred to A corporation whose stock was distributed to petitioner and another in exchange for their stock of S corporation. Thereafter, activities…

1Opinion of the Court

Andrew M. Spheeris and Ismene A. Spheeris, Petitioners v. Commissioner of Internal Revenue, Respondent

Spheeris v. Commissioner

Docket No. 7183-65

United States Tax Court

54 T.C. 1353; 1970 U.S. Tax Ct. LEXIS 107;

June 23, 1970, Filed

Decision will be entered under Rule 50.

The S corporation had been engaged in the business of owning and operating commercial rental properties since 1945. In February 1960, one of its properties was destroyed by fire. Thereafter, various activities were engaged in on behalf of S corporation directed toward returning such property to income-producing status. Because of…

2Cases cited5 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Commissioner v. GordonSupreme Court of the United States · 1968
  3. Coady v. CommissionerUnited States Tax Court · 1960
  4. United States v. W. W. Marett and Ruth MarettCourt of Appeals for the Fifth Circuit · 1963
  5. Spheeris v. CommissionerUnited States Tax Court · 1970

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